28 January 2016 EPA Far West Operations Attention: Michelle Gibson Email: [email protected] RE: BODANGORA WIND FARM – MP10_0157 – MOD 1 I am a retiree living at Wellington. I started general noise testing in 1969, working for 41 years in a testing laboratory called Testing & Certification Australia (“TCA”), which was a division of Energy Australia based in Sydney. Most of the latter part of that time I was an authorised National Association of Testing Authorities (“NATA”) Signatory in Transformer and/or Community Noise Assessment. When I was evaluating complaints against Energy Australia, I was obliged to err on the side of the worst case scenario using maximum penalties. Energy Australia was happy with that, as they wanted to modernise the reliability of their network and improve the quality of life by working with various committees together with Noise Pollution Control Board (todays EPA) progressively amending and/or introducing new Specifications and Australian Standards as technology advanced. Energy Australia had no wind turbines and TCA was not involved in infrasound research. We knew that using dB(A) scaled instruments was not fair, as it mismatched the frequency and amplitude dosage responses. Fortunately a New Zealand company has recently developed an infrasound dosimeter. A few weeks ago they were performing successful demonstrations and far reaching experiments at Lithgow. Was EPA Far West involved? My measurements were occasionally crossed checked by EPA field officers, who came to find out which of the available half a dozen 5dB(A) noise penalties were applicable, with maximum penalty of 10dB(A). In addition to the regular low frequency transformer noise penalty, they were specifically concerned in the intermittent off-peak hot water heating system load control motor/generator sets providing control signals at 750Hz and/or 1050Hz super imposed to the customer’s mains. These motor/generator sets were normally located in separate buildings inside substation yards. They produced loud wide band airborne noises as well as harmonics noises induced into the substation transformers. Because transformer noise was Energy Australia’s main concern, we developed a time averaging technique by tape recording a mains sampling signal for the playback data processing, which facilitated detecting narrow band transformer noises better than the one third octave band system of EPA under poor signal to background noise ratios. I often helped EPA with their transformer noise enquiries. I have only positive and constructive memories working with the EPA officers. The reason that they attended actual sites with me was that, after they had given me copies of all their noise compliance requirements, definitions and field working manuals, they wanted to witness my testing procedures and keep me “honest” by comparing the results using their own instruments on the same windless and cloudless nights under the same temperature inversion conditions. These inversions were determined by the duty forecaster of the Bureau of Meteorology and for most metropolitan suburbs overnight between 10pm and 6am were often in the range of 5dB(A) to 10dB(A). To my knowledge this service has been discontinued. I have noise tested just about all Energy Australia’s zone substations up to year 2010 and hundreds of kiosk substations and all types of pole transformers. Just to drop some names, I was head hunted to noise test the transformers that went to Sydney Opera House, the Snowy Mountain Scheme and Sydney Olympic Stadium. I have also solved at least 100 noise complaints to customer’s satisfaction. During the olden days with only basic instrumentation the hardest part of the noise work at night was to get the right background value into which all the various character adjusted measured values were compared and exceedances determined. There was a time when the EPA insisted that the A-weighted L95 was used and if the measured values were less than the traffic related reference lookup table ‘R-values’, the lowest measured values were to be used for the background. Today’s ‘deemed’ minimum allowable background of 30dB(A) makes a mockery of the quality of life in quiet rural backgrounds where L90 values using modern instruments are typically from 18dB(A) to 25dB(A). For example, some residents 5 km away from the Uranquinty gas fired power station, which is improperly located on the edge of the town, come to town to get noise annoyance relief. The actual offending noise is louder in the town than at their home, but because the town’s background is also substantially higher, the lower excess over the town’s background gives them some relief from subjectively higher annoyance at home, where the farmer ‘hears’ only the excess over his own true quiet background not the excess over the deemed guidelines. The ‘worse’ situation in town ‘feels’ better to him. In Australia, when there would be several individual 5dB(A) penalties, wind farms have been given a grace of maximum penalty of a single 5dB(A) only. To my knowledge wind farms have never been penalised in Australia. Even the noise policy says that, if the proponent cannot prove that the ‘amplitude modulation’ (which term the proponent wants to use without admitting tonality penalty) at the blade passing frequency is not less than 4dB(A), a penalty of 5dB(A) must be added to the predicted or measured noise levels. It is my understanding that Infigen Energy (“Infigen”) has not yet applied for an Environment Protection Licence (“EPL”) for the Bodangora Wind Farm so you have not been able to start your technical evaluation for the above project. Background Wind power is not squeaky clean “sustainable” free energy. Wherever it has been introduced to the public, total cost of electrical energy has gone up. Wind farms around the world survive temporarily only in the current political climate due to enormous government subsidies. Some of the “puppet masters” who control the electricity grid even allow Wind Farms to pay them to supply the power during windy conditions when there is excess supply, thereby creating massive problems for other baseload suppliers. During the calm periods Wind Farms are unable to meet demand. Consequently, the baseload providing system must be kept up to date and technologically efficient and capable of supplying 100% of the power, making Wind Farms a superfluous cost burden. The grid is not a warehouse of electrical power, which parasitic wind turbines can top-up with random bursts of poorly frequency controlled energy with harmonic distortion, which utility companies do not want. There are various adverse effects. It has been reported that in Europe alone at the end of 2015, there are 890 organisations registered under the European Platform Against Windfarms (“EPAW”) trying to expose them. The wind industry is still in its infancy and the future deserted graveyards of ‘triangular lightning masts’ are not yet visible in bulk. In Denmark, the home of Vestas, the average age of Vestas turbines which have been terminated is 17 years. There has not yet been enough time for large scale comprehensive adverse long term controlled clinical studies. Proponents get away by claiming that failure of adverse non-evidence is evidence of non-failure. Infigen’s original poorly drafted project application for Bodangora Wind Farm was only generic. The noise predictions were made using reverse engineering. By knowing what the end receiver compliance values are, the noise source values are predicted to be low to meet these requirements regardless of what the actual measured values from other Infigen Wind Farm sites are after construction. The nearby Bodangora community is polarised between non-associated and associated farmers, who are not talking to each other. Non-associated farmers are worried about adverse effects and reduced land values, while the associated landowners are laughing all the way to the bank, after selling their souls, as the long term adverse effects have not started to cumulate yet. MP 10_0157, the Bodangora Wind Farm Project, has been on foot since 2010 and was approved by the Planning Assessment Commission on 30 August 2013 under controversial circumstances. It was subsequently modified in October 2015 after an inadequate application was accepted by the Department of Planning. I did not become involved in evaluating the noise data until a long time after the Modifications were issued. Here are some generic steps Infigen may have used at Wellington: 1. The proponent approached the local council offering a Community Benefit Scheme for various local charities, clubs and sporting clubs. A Voluntary Planning Agreement was entered into that contained further promises of road maintenance as well as promises of hundreds of local jobs during the construction phase and generous compensation to associated landowners. 2. The proponent sent a vague project application to the NSW Department of Planning and Infrastructure (“the Department”) 3. There was no need for rigorous assessment by the Department as the wind farm projects are heavily desired and subsidised by the Government and the Proponent is happy to assemble and the Council is happy to receive whatever turns up from various manufactures. 4. Conditional approval is granted by the Planning Assessment Commission (“PAC”) despite strong opposition from nearby landowners, the Wellington Correctional Centre and Wellington businesses and residents. 5. A Community Consultative Committee is formed but in reality it is not representative of the Wellington community. It is nothing more than another vehicle to mask the dangers of the Wind Farm at this location 6. As the Wind Farm could not be made noise compliant for the nearest residences, they are shut up and bought out to become associated proponents. They lease their land to Infigen and receive a substantial lease payment per year for the life of the Project. What happens after that is unclear.